Spyglass Partners, Richard E. Shea, Tax Matters Partner, et al. - Page 27

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          interest provisions.  The December agreements did not contain               
          default provisions.  The parties made the simple, but all-                  
          encompassing statement:  "All of the burdens and benefits of                
          ownership of the subject property are transferred from * * *                
          [seller] to * * * [buyer] as of the date of this Agreement."                
          Further, the sellers placed in escrow all deeds relating to the             
          transfer of the property which were to be recorded by the escrow            
          agent on the designated closing date of July 2, 1984.                       
               Accordingly, at the time of the execution of the December              
          agreements, the buyers had not waived the specific performance              
          remedy.  That waiver occurred in connection with the superseding            
          May agreements in which a $50,000 liquidated damages note was               
          executed and exchanged.  The waiver of specific performance,                
          along with the liquidated damages provisions, did change the                
          partnerships' remedies.  At the time of the change, however, the            
          partnerships had exercised possession and control over the                  
          condominiums.  Furthermore, financing had been arranged, and the            
          closing was imminent (about 1 month distant).  Under these                  
          circumstances, respondent contends that the substance of the                
          transaction prior to the closing indicated an option.  However,             
          Utah law causes us to find that the transactions resulted in                
          equitable title or interests in the partnerships (buyers) as of             
          December 1983.                                                              
               Substance Over Form.  Having analyzed several factors, we              
          have concluded that, under Utah law, the December agreements                



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